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Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 1 of 135 PageID #:
`144
`
`IN THE UNITED STATES DISTRICT COURT FOR
`THE DISTRICT OF DELAWARE
`
`PARUS HOLDINGS INC.
`
`Plaintiff,
`
`Civil Action No. _______
`
`v.
`
`AMAZON.COM, INC.
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`COMPLAINT
`
`1.
`
`Plaintiff Parus Holdings Inc. (“Parus” or “Plaintiff”) files this complaint for patent
`
`infringement against Defendant Amazon.com, Inc. (“Amazon” or “Defendant”) for infringement
`
`of U.S. Patent No. 7,516,190 (“the ’190 patent”), U.S. Patent No. 9,377,992 (“the ’992 patent”),
`
`and U.S. Patent No. 10,320,981 (“the ’981 patent”) (collectively the “patents-in-suit”), pursuant
`
`to 35 U.S.C. § 271 (copies of the patents-in-suit are attached as Exhibits A, B, and C, respectively).
`
`PARTIES
`
`2.
`
`Plaintiff Parus Holdings Inc. is a Delaware corporation having its principal place
`
`of business at 3000 Lakeside Drive, Suite 110S, Bannockburn, IL 60015.
`
`3.
`
`Defendant Amazon.com, Inc. is a company organized and existing under the laws
`
`of the State of Delaware with a principal place of business located at 410 Terry Avenue North,
`
`Seattle, Washington 98109-5210. Amazon may be served via its registered agent, Corporation
`
`Service Company, 251 Little Falls Drive, Wilmington, Delaware 19808.
`
`4.
`
`The patents-in-suit are infringed by Amazon’s Alexa devices and associated
`
`servers, including for example those identified in Section V and all structurally/functionally similar
`
`devices.
`
`

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`JURISDICTION AND VENUE
`
`5.
`
`This is an action for patent infringement under the patent laws of the United States,
`
`35 U.S.C. §271. This court has federal jurisdiction of such federal question claims pursuant to 28
`
`U.S.C. §§1331 and 1338(a).
`
`6.
`
`The Court has personal jurisdiction over Amazon consistent with the requirements
`
`of the Due Process Clause of the United States Constitution and the Delaware Long-Arm Statute.
`
`Amazon has regularly and systematically transacted business in Delaware, directly or through
`
`subsidiaries or intermediaries, and/or committed acts of patent infringement in Delaware as alleged
`
`more particularly below. Amazon has placed infringing products into the stream of commerce by
`
`shipping those products into Delaware or knowing that the products would be shipped into
`
`Delaware.
`
`7.
`
`Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b) because,
`
`among other things, Amazon has transacted business in the District of Delaware and has committed
`
`acts of direct infringement in the District of Delaware.
`
`BACKGROUND
`
`8.
`
`Since its founding, Parus has offered a robust diversity of products and services to
`
`customers in a wide variety of markets. Parus’ products and services have included audio and
`
`video conferencing, email management, voice messaging, polling and transcription, IM/presence,
`
`collaboration, softphone, and virtual assistant solutions and services. For example, ParusOne
`
`provides voice-response technology solutions for customers and other users to manage
`
`communication technology used for business from laptops, mobile phones, and home offices to
`
`answer calls, handle voice mails, faxes and emails, schedule meetings, and establish conference
`
`calls. ParusOffice enables small businesses to channel their various phone communications
`
`through one main number. ParusSpeak provides interactive voice response solutions for companies
`
`-2-
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`

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`that need business process automation, as well as automated name, address, and caller feedback
`
`capture. ParusMobile provides worldwide group messaging for direct selling organizations, mobile
`
`professionals, and small business customers. Parus’ customers have included businesses in
`
`network marketing, manufacturing, financial services, retail, healthcare, customer care, and direct
`
`response industries. Parus has had dozens of customers in this judicial district.
`
`9.
`
`Parus’ systems have also received accolades from the industry, including some of
`
`the most preeminent awards in the CRM, call center, and teleservice fields. For example, ParusOne
`
`was named the 2007 Product of the Year by both Internet Telephony and from Unified
`
`Communications; Parus Marketing Campaign Manager was named the 2007 Product of the Year
`
`by Customer Interaction Solutions; and Webley MD Reminders was named the Product of the
`
`Year in both 2009 and 2010 by Customer Interaction Solutions.
`
`THE ASSERTED PATENTS
`
`10.
`
`On April 7, 2009, the United States Patent and Trademark Office issued U.S. Patent
`
`No. 7,516,190, the ’190 patent, entitled “Personal Voice-Based Information Retrieval System,”
`
`after full and fair examination. Plaintiff is the assignee of all rights, title, and interest in and to the
`
`’190 patent and possesses all rights of recovery under the ’190 patent, including the right to recover
`
`damages for present, past, and future infringement. The ’190 patent expired on May 10, 2022, but,
`
`pursuant to 35 U.S.C. § 286, Plaintiff is entitled to recover damages for any infringement by
`
`Amazon committed less than six years prior to the filing of this Complaint. A true and correct copy
`
`of the ’190 patent is attached as Exhibit A. The ’190 patent is valid and enforceable.
`
`11.
`
`On June 28, 2016, the United States Patent and Trademark Office issued U.S. Patent
`
`No. 9,377,992, the ’992 patent, entitled “Personal Voice-Based Information Retrieval System,”
`
`after full and fair examination. Plaintiff is the assignee of all rights, title, and interest in and to the
`
`’992 patent and possesses all rights of recovery under the ’992 patent, including the right to recover
`
`-3-
`
`

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`damages for present, past, and future infringement. The ’992 patent expired on November 16,
`
`2022, but, pursuant to 35 U.S.C. § 286, Plaintiff is entitled to recover damages for any infringement
`
`by Amazon committed less than six years prior to the filing of this Complaint. A true and correct
`
`copy of the ’992 patent is attached as Exhibit B. The ’992 patent is valid and enforceable.
`
`12.
`
`On June 11, 2019, the United States Patent and Trademark Office issued U.S. Patent
`
`No. 10,320,981, the ’981 patent, entitled “Personal Voice-Based Information Retrieval System,”
`
`after full and fair examination. Plaintiff is the assignee of all rights, title, and interest in and to the
`
`’981 patent and possesses all rights of recovery under the ’981 patent, including the right to recover
`
`damages for present, past, and future infringement. The ’981 patent expired on February 6, 2021,
`
`but, pursuant to 35 U.S.C. § 286, Plaintiff is entitled to recover damages for any infringement by
`
`Amazon committed less than six years prior to the filing of this Complaint. A true and correct copy
`
`of the ’981 patent is attached as Exhibit C. The ’981 patent is valid and enforceable.
`
`CLAIMS FOR PATENT INFRINGEMENT
`
`13.
`
`In the interest of providing detailed averments of infringement, Plaintiff has
`
`identified below at least one claim per patent-in-suit to demonstrate infringement by at least one
`
`product. However, the selection of claims and products below should not be considered limiting,
`
`and infringement by Amazon by way of additional claims of the patents-in-suit and additional
`
`products will be disclosed in compliance with the Court’s rules related to infringement contentions
`
`and/or discovery. The allegations provided below are exemplary and without prejudice to
`
`Plaintiff’s infringement contentions to be provided pursuant to the Court’s scheduling order, local
`
`rules, and/or discovery procedures. Plaintiff’s claim construction contentions regarding the
`
`meaning and scope of the claim terms will be provided under the Court’s scheduling order, local
`
`rules, and/or discovery procedures. As detailed below, each element of at least one claim of each
`
`of the patents-in-suit is literally present in at least one accused product. To the extent that any
`
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`element is not literally present, each such element is present under the doctrine of equivalents.
`
`Plaintiff’s analysis below should not be taken as an admission and/or contention that the preamble
`
`for any claim is or is not limiting. While publicly available information is cited below, Plaintiff
`
`may rely on other forms of evidence to show infringement.
`
`14.
`
`The accused products include at least the following smart speaker products
`
`incorporating Amazon’s Alexa from 2017 to the present, as well as products with reasonably
`
`similar functionality and all varieties of these products. Specific identification of the accused
`
`products will be provided in plaintiff’s infringement contentions pursuant to the Court’s
`
`scheduling order, local rules, and/or discovery procedures.
`
` Echo (all generations);
`
` Echo dot (all generations);
`
` Amazon Tap;
`
` Echo Look;
`
` Echo Show;
`
` Echo Spot;
`
` Echo Plus;
`
` Echo Flex; and
`
` Echo Auto.
`
`15.
`
`Amazon has directly and indirectly infringed the patents-in-suit by having engaged
`
`in acts constituting infringement under 35 U.S.C. § 271(a), including but not necessarily limited
`
`to one or more of making, using, selling and offering to sell, in this district and elsewhere in the
`
`United States, and importing into and exporting from the United States, the accused products or
`
`components thereof.
`
`-5-
`
`

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`16.
`
`Amazon has had knowledge of the patents-in-suit since prior to the date of this
`
`Complaint.
`
`17.
`
`Amazon’s acts of infringement have caused damage to Parus. Parus is entitled to
`
`recover from Amazon the damages sustained by Parus as a result of Amazon’s wrongful acts in an
`
`amount subject to proof at trial.
`
`COUNT ONE: PATENT INFRINGEMENT OF THE ’190 PATENT
`
`18.
`
`Parus incorporates by reference the preceding paragraphs as if fully stated herein.
`
`19.
`
`Claim 1 of the ’190 patent is reproduced below:
`
`1. A method for allowing users to use speech commands to obtain
`information from a pre-defined portion of a pre-selected web site in
`audio format, said method comprising the steps of:
`
`(a) providing a computer having a speech processor, said computer
`being operatively connected to the internet and to at least one phone;
`
`(b) providing a URL to said computer, said URL indicating a pre-
`selected web site from which the information is to be retrieved;
`
`(c) using said computer to designate a pre-defined portion of the pre-
`selected web site which contains the information to be retrieved;
`
`(d) using said computer to identify a named object associated with the
`content of the information to be retrieved;
`
`(e) using said computer to generate a regular expression based on said
`pre-defined portion of said pre-selected web site and said named object,
`said regular expression corresponding to said content of said
`information to be retrieved, wherein said regular expression is a text
`string used for describing a search pattern;
`
`(f) providing a speech command to said speech processor, said speech
`command corresponding to said regular expression;
`
`(g) said speech processor converting said speech command to a digital-
`form command;
`
`(h) said computer receiving said digital-form command from said
`speech processor, said computer assigning said regular expression to
`said digital-form command;
`
`-6-
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`(i) after steps (a) through (h) are completed, transmitting an audio
`speech command to said speech processor, said speech command
`corresponding to said regular expression;
`
`(j) said speech processor converting said speech command to said
`digital-form command;
`
`(k) said computer receiving said digital-form command from said
`speech processor;
`
`(l) said computer retrieving said regular expression corresponding to
`said digital-form command;
`
`(m) said computer retrieving the information from the pre-defined
`portion of the pre-selected web site corresponding to said regular
`expression when the requested information is found in the pre-defined
`portion of the pre-selected website;
`
`(n) said computer searching said pre-selected web site for said named
`object when the requested information is not found in the pre-defined
`portion of the pre-selected web site;
`
`(o) said computer providing said retrieved information to said speech
`processor;
`
`(p) said speech processor converting said retrieved information into an
`audio message; and
`
`(q) said speech processor forwarding said audio message to a user.
`
`20.
`
`Using its accused products, Amazon performed a method for allowing users to use
`
`speech commands to obtain information from a pre-defined portion of a pre-selected web site in
`
`audio format as specified by claim 1. Amazon accused products used to infringe claim 1 (and/or
`
`any other claims in the patent) are herein collectively the “’190 accused products.” In the
`
`following, infringement by way of an Amazon Echo device is illustrated to provide non-limiting
`
`examples of Amazon’s infringement of the ’190 patent.
`
`21.
`
`The ’190 patent claim 1 begins, “A method for allowing users to use speech
`
`commands to obtain information from a pre-defined portion of a pre-selected web site in audio
`
`format, said method comprising the steps of.” As non-limiting examples, Amazon performed this
`
`method using Amazon Echo smart speaker devices.
`
`-7-
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`

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`22.
`
`The Amazon Alexa system included the Alexa cloud based service and at least one
`
`Alexa compatible remote device such as the Amazon Echo smart speaker. The Amazon Alexa
`
`system performed a method for allowing users to use speech commands to obtain information from
`
`a pre-defined portion of a pre-selected web site in audio format.
`
`https://web.archive.org/web/20201111235237/https://developer.amazon.com/en-US/alexa
`(Internet archive, Sep. 2019).
`
`
`
`
`
`https://web.archive.org/web/20200817142721/https://developer.amazon.com/en-US/alexa/alexa-
`skills-kit/get-deeper (Internet archive, Mar. 2020)
`
`-8-
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`

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`
`
`
`
`
`
`https://web.archive.org/web/20160131082954/http://www.amazon.com/Amazon-SK705DI-
`Echo/dp/B00X4WHP5E (Internet archive, Jun. 2015)
`
`Source: https://www.youtube.com/watch?v=VQVZ2hvNVfo
`
`
`
`23.
`
`The ’190 patent claim 1 further recites, in subsection (a), “(a) providing a computer
`
`having a speech processor, said computer being operatively connected to the internet and to at least
`
`one phone.” As non-limiting examples, Amazon provided a computer having a speech processor,
`
`-9-
`
`

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`said computer being operatively connected to the internet and to at least one phone that operated
`
`with the Alexa Echo smart speakers.
`
`24.
`
`For example, as shown below, the Amazon Alexa system included a computer
`
`having a speech processor in the form of the Alexa Voice Service. The Amazon Alexa system
`
`was also accessible by a phone application.
`
`https://web.archive.org/web/20160131082954/http://www.amazon.com/Amazon-SK705DI-
`Echo/dp/B00X4WHP5E (Internet archive, Jun. 2015)
`
`
`
`Source: https://www.youtube.com/watch?v=VQVZ2hvNVfo
`
`
`
`-10-
`
`

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`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`
`https://web.archive.org/web/20201030024213/https://developer.amazon.com/en-
`US/docs/alexa/flashbriefing/steps-to-create-a-flash-briefing-skill.html (Internet archive Nov.
`2020)
`
`
`25.
`
`The ’190 patent claim 1 further recites, in subsection (b), “(b) providing a URL to
`
`said computer, said URL indicating a pre-selected web site from which the information is to be
`
`retrieved.” As non-limiting examples, Amazon provided a URL to the computer described above,
`
`
`
`said URL indicating a pre-selected web site from which the information is to be retrieved.
`
`-11-
`
`

`

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`26.
`
`For example, a skill developer provided a URL to the Amazon Alexa system that
`
`indicated a pre-selected web site where information was be retrieved. For example, the Tide Pool
`
`skill
`
`retrieved a portion of
`
`the
`
`information
`
`from
`
`the web
`
`site at
`
`the URL
`
`http://tidesandcurrents.noaa.gov/. Amazon similarly acted as a skill developer for its own Amazon-
`
`created skills.
`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`27.
`
`The ’190 patent claim 1 further recites, in subsection (c), “(c) using said computer
`
`to designate a pre-defined portion of the pre-selected web site which contains the information to
`
`be retrieved.” As non-limiting examples, Amazon used the computer described above to designate
`
`a pre-defined portion of the pre-selected web site which contains the information to be retrieved.
`
`28.
`
`For example, a skill developer provided code/instructions to the Amazon Alexa
`
`system that designated a pre-defined portion of the pre-selected web site which contained the
`
`information to be retrieved. The Tide Pool skill accesses a portion of the web site at
`
`http://tidesandcurrents.noaa.gov/. Amazon similarly acted as a skill developer for its own Amazon-
`
`created skills.
`
`-12-
`
`

`

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`156
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`29.
`
`The ’190 patent claim 1 further recites, in subsection (d), “(d) using said computer
`
`to identify a named object associated with the content of the information to be retrieved.” As non-
`
`limiting examples, Amazon used the computer described above to identify a named object
`
`
`
`associated with the content of the information to be retrieved.
`
`30.
`
`On information and belief, a skill developer (such as the Tide Pool skill developer)
`
`provided code/instructions to the Amazon Alexa system that identified a named object associated
`
`with the content of the information to be retrieved. Amazon similarly acted as a skill developer for
`
`its own Amazon-created skills.
`
`31.
`
`The ’190 patent claim 1 further recites, in subsection (e), “(e) using said computer
`
`to generate a regular expression based on said pre-defined portion of said pre-selected web site
`
`and said named object, said regular expression corresponding to said content of said information
`
`to be retrieved, wherein said regular expression is a text string used for describing a search pattern.”
`
`As non-limiting examples, Amazon used the computer described above to generate a regular
`
`expression based on said pre-defined portion of said pre-selected web site and said named object,
`
`-13-
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`said regular expression corresponding to said content of said information to be retrieved, wherein
`
`said regular expression is a text string used for describing a search pattern.
`
`32.
`
`On information and belief, a skill developer, such as at Amazon, provided
`
`code/instructions to the Amazon Alexa system that generated and used a regular expression
`
`associated with the content of the information to be retrieved.
`
`33.
`
`The ’190 patent claim 1 further recites, in subsection (f), “(f) providing a speech
`
`command to said speech processor, said speech command corresponding to said regular
`
`expression.” As non-limiting examples, Amazon provided a speech command to said speech
`
`processor, said speech command corresponding to said regular expression.
`
`34.
`
`For example, a skill developer at Amazon provided sample utterances. On
`
`information and belief, the sample utterances corresponded to said regular expression.
`
`
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`-14-
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`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`35.
`
`The ’190 patent claim 1 further recites, in subsection (g), “(g) said speech processor
`
`converting said speech command to a digital-form command.” As non-limiting examples,
`
`Amazon’s speech processor converted said speech command to a digital-form command.
`
`36.
`
`For example, a skill developer provided intents as a digital-form command.
`
`
`
`-15-
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`159
`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`37.
`
`The ’190 patent claim 1 further recites, in subsection (h), “(h) said computer
`
`receiving said digital-form command from said speech processor, said computer assigning said
`
`regular expression to said digital-form command.” As non-limiting examples, Amazon’s computer
`
`received said digital-form command from said speech processor, and said computer assigned said
`
`regular expression to said digital-form command.
`
`38.
`
`On information and belief, Amazon assigned the Amazon Alexa regular expression
`
`to a digital form command.
`
`39.
`
`The ’190 patent claim 1 further recites, in subsection (i), “(i) after steps (a) through
`
`(h) are completed, transmitting an audio speech command to said speech processor, said speech
`
`command corresponding to said regular expression.” As non-limiting examples, Amazon, after
`
`having completed steps (a) through (h), transmitted an audio speech command to said speech
`
`processor, said speech command corresponding to said regular expression.
`
`40.
`
`On information and belief, an Amazon Alexa speech command corresponded to
`
`said regular expression. For example, the user request (speech command) was transmitted to the
`
`Alexa system AVS.
`
`-16-
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`Source: https://www.youtube.com/watch?v=VQVZ2hvNVfo
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`-17-
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`
`
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`

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`161
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`
`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`-18-
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`
`
`https://www.codemag.com/article/1805081/Building-an-Alexa-Skill-with-AWS-Lambda
`
`41.
`
`The ’190 patent claim 1 further recites, in subsection (j), “(j) said speech processor
`
`converting said speech command to said digital-form command.” As non-limiting examples,
`
`Amazon’s speech processor converted said speech command to said digital-form command.
`
`42.
`
`For example, the Amazon intents were a digital-form command.
`
`
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`-19-
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`163
`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`43.
`
`The ’190 patent claim 1 further recites, in subsection (k), “(k) said computer
`
`receiving said digital-form command from said speech processor.” As non-limiting examples,
`
`Amazon’s computer received said digital-form command from said speech processor.
`
`44.
`
`For example, the Amazon intents were a digital-form command.
`
`
`
`-20-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 21 of 135 PageID #:
`
`164
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`
`
`
`
`https://www.codemag.com/article/1805081/Building-an-Alexa-Skill-with-AWS-Lambda
`
`45.
`
`The ’190 patent claim 1 further recites, in subsection (l), “(l) said computer
`
`retrieving said regular expression corresponding to said digital-form command.” As non-limiting
`
`examples, on information and belief, Amazon’s computer retrieved said regular expression
`
`corresponding to said digital-form command.
`
`46.
`
`The ’190 patent claim 1 further recites, in subsection (m), “(m) said computer
`
`retrieving the information from the pre-defined portion of the pre-selected web site corresponding
`
`to said regular expression when the requested information is found in the pre-defined portion of
`
`the pre-selected website.” As non-limiting examples, Amazon’s computer retrieved the
`
`information from the pre-defined portion of the pre-selected web site corresponding to said regular
`
`-21-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 22 of 135 PageID #:
`
`165
`
`expression when the requested information is found in the pre-defined portion of the pre-selected
`
`website.
`
`47.
`
`On information and belief, the Amazon Alexa system retrieved information from
`
`the pre-defined portion of the pre-selected web site that corresponded to said regular expression.
`
`The particular Alexa skill retrieved a pre-defined portion of the pre-selected web site.
`
`48.
`
`For example, the Tide Pool skill accesses a portion of the web page at
`
`http://tidesandcurrents.noaa.gov/. Amazon similarly acted as a skill developer for its own Amazon-
`
`created skills.
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`
`
`-22-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 23 of 135 PageID #:
`
`166
`
`
`
`https://www.codemag.com/article/1805081/Building-an-Alexa-Skill-with-AWS-Lambda
`
`49.
`
`The ’190 patent claim 1 further recites, in subsection (n), “(n) said computer
`
`searching said pre-selected web site for said named object when the requested information is not
`
`found in the pre-defined portion of the pre-selected web site.” As non-limiting examples, on
`
`information and belief, Amazon’s computer searched said pre-selected web site for said named
`
`object when the requested information was not found in the pre-defined portion of the pre-selected
`
`web site.
`
`50.
`
`The ’190 patent claim 1 further recites, in subsection (o), “(o) said computer
`
`providing said retrieved information to said speech processor.” As non-limiting examples,
`
`Amazon’s computer provided said retrieved information to said speech processor.
`
`51.
`
`For example, the Tide Pool skill provided the retrieved information to the AVS.
`
`http://tidesandcurrents.noaa.gov/. Amazon similarly acted as a skill developer for its own Amazon-
`
`created skills.
`
`(i)
`
`The API call would be an instruction
`
`(ii)
`
`The Alexa skill would process the returned information from the website to
`
`extract/format the requested information.
`
`-23-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 24 of 135 PageID #:
`
`167
`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`52.
`
`The ’190 patent claim 1 further recites, in subsection (p), “(p) said speech processor
`
`converting said retrieved information into an audio message.” As non-limiting examples,
`
`Amazon’s speech processor converted said retrieved information into an audio message.
`
`53.
`
`For example, the Alexa Voice Service included a speech-synthesis engine, where
`
`the Alexa Voice Service converted the returned text to speech.
`
`-24-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 25 of 135 PageID #:
`
`168
`
`Source: https://www.youtube.com/watch?v=VQVZ2hvNVfo
`
`-25-
`
`
`
`
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 26 of 135 PageID #:
`
`169
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`
`
`
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`54.
`
`The ’190 patent claim 1 further recites, in subsection (q), “(q) said speech processor
`
`forwarding said audio message to a user.” As non-limiting examples, Amazon’s speech processor
`
`forwarded said audio message to a user.
`
`55.
`
`For example, the Alexa Voice Service included a speech-synthesis engine, where
`
`the Alexa Voice Service converted the returned text to speech and transmitted it to the user.
`
`-26-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 27 of 135 PageID #:
`
`170
`
`Source: https://www.youtube.com/watch?v=VQVZ2hvNVfo
`
`
`
`-27-
`
`
`
`
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 28 of 135 PageID #:
`
`171
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`56.
`
`For example, the Tide Pool skill accesses a portion of the web page at
`
`http://tidesandcurrents.noaa.gov/. Amazon similarly acted as a skill developer for its own Amazon-
`
`created skills.
`
`https://web.archive.org/web/20201112015825/https://developer.amazon.com/en-
`US/docs/alexa/custom-skills/understanding-custom-skills.html (Internet archive Nov. 2020)
`
`
`57.
`
`The above provides non-limiting examples of Amazon’s infringement of claim 1
`
`of the ’190 patent. As asserted in this action, Amazon infringes additional claims in the ’190 patent,
`
`
`
`with the specific infringement contentions to be presented in discovery per the Court’s procedure.
`
`COUNT TWO: PATENT INFRINGEMENT OF THE ’992 PATENT
`
`58.
`
`Parus incorporates by reference the preceding paragraphs as if fully stated herein.
`
`59.
`
`Claim 1 of the ’992 patent is reproduced below:
`
`1. A method for retrieving information from an information source using speech
`commands by a user provided via an electronic communication device, said
`method comprising steps of:
`
`the electronic
`the user via
`receiving a speech command from
`communication device at a speech recognition engine coupled to a media
`
`-28-
`
`

`

`Case 1:23-cv-00190-GBW-CJB Document 1 Filed 02/17/23 Page 29 of 135 PageID #:
`
`172
`
`server, the media server configured to identify and access the information
`source via a network, wherein the speech recognition engine selects
`recognition grammar established to correspond to the speech command and
`wherein the information source is periodically updated with information;
`
`selecting, by the media server, at least one appropriate information source
`retrieval instruction corresponding to the recognition grammar established
`for the speech command, wherein the at least one appropriate information
`source retrieval instruction is stored in a database associated with the server;
`
`accessing, by a web browsing server, a portion of the information source
`including only a portion of information previously identified by the user of
`interest to the user by using a clipping client to separate the portion of the
`information from other information, wherein the clipping client generates a
`content descriptor file containing a description of content of the portion of
`information and wherein the content descriptor file indicates where the
`portion of the information selected is located within the information source
`and retrieving only the portion of the information according to the at least
`one appropriate information source retrieval instruction;
`
`converting the information retrieved from s

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